Bower v. HansmanThe Trial Court issued a Final Judgment of Paternity which calculated child support by including the mother's child support, from another child, in her net income. The Fifth District reversed and noted the long-standing rule that child support is not income for any purpose, including the calculation of net income for purposes of determining support obligations of other children. NOTE: pursuant to Florida Statute 61.30 the Court must deduct support paid, per court order, for children of another relationship from the determination of a payer's income. Ballard v. BallardThe general rule that use of marital funds to pay-down the mortgage on a non-marital property was not disturbed by the Florida Supreme Court's recent decision in Kaaa v. Kaaa. That decision held that where marital funds are contributed to the pay-down of the mortgage, a pro rata share of any passive appreciation should be considered marital as well. This decision re-affirms that the equity created by the Kaaa holding is not exclusive, it is cumulative to the general rule that the balance reduction on a mortgage which arises from marital payments creates a marital interest.